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Personal Data Protection Disclosure Statement (KVKK Disclosure Statement)

Data Controller Information:
As Viofun Yazılım A.Ş. (“Company” or “Viofun”), we act as a data controller pursuant to the Turkish Personal Data Protection Law No. 6698 (“KVKK”). Our company details are as follows:

Address:
AOSB 3. Kısım Mah. 40. Cad. No:4, İç Kapı No: Z01, Döşemealtı / Antalya, Turkey
Phone: +90 850 777 0 846
Email: [email protected]

This Disclosure Statement has been prepared to inform you about the processing of your personal data in accordance with Article 10 of KVKK. Viofun reserves the right to update this document in line with applicable legal regulations.


Personal Data Processed

When you use our platform (including www.viofun.com, www.violocal.com, and our mobile apps) or become a member, we may process the following categories of personal data:

  • Identity Information: Name, surname, date of birth, national ID number (for local users), or passport number (for foreign users).

  • Contact Information: Email address, phone number, postal address.

  • Account Information: Username, membership ID, password (stored securely), profile photo (if provided), and account preferences.

  • Payment Information: Credit card details (e.g., cardholder name, masked card number, expiration date, CVV) and authorization codes. Note: Full credit card data is not stored by Viofun but securely processed by authorized payment institutions.

  • Transaction Security Data: IP address, login/logout logs, encrypted device information, and cookies collected during use.

  • Usage and Preference Data: Search history, favorites, past bookings, shopping cart contents, viewed content.

  • Location Data: Approximate location or GPS data, if voluntarily shared through our mobile app.

  • Marketing Data: Records of electronic communications (e.g., emails, SMS) sent with your consent, campaign participation details, and interest-based data collected via cookies.

Not all data categories listed above are applicable to every user. For example, if you only browse our content, payment data will not be processed. However, if you make a purchase, your booking and transaction data will be collected.


Purposes of Personal Data Processing

Your personal data is processed in accordance with Articles 5 and 6 of KVKK for the following purposes:

  • Provision of Services & Platform Operations: To deliver mobile apps, software services, digital content, and online ticketing via our platform; to manage user accounts; to fulfill bookings and ticket purchases. For instance, if you buy a ticket, your data may be shared with the event or tour provider to confirm your reservation.

  • Communication & Customer Support: To provide service notifications (e.g., booking confirmations, ticket deliveries, schedule changes), respond to inquiries, and offer technical support. Platform updates may be sent to your registered contact details.

  • Legal Compliance & Security: To log transactions for accountability, use as legal evidence if needed, prevent fraudulent or unauthorized actions, and ensure system security. For example, if suspicious activity is detected, we may suspend your account and contact you.

  • Service Quality & Improvement: To enhance our platform and services through behavior analytics. Cookies and other tracking tools are used to understand which content is most engaging and to optimize user experience.

  • Marketing & Campaigns: With your explicit consent, we may process your data to share relevant campaigns and offers via email or app notifications. You may opt out of such communications at any time.

  • Legal Obligations: We may process data when required by legal regulations, such as those outlined in the Consumer Protection Law, Distance Sales Regulation, E-Commerce Law, and Tax Procedure Law, to maintain records or respond to official requests.

  • Legitimate Interests: Your data may be processed where necessary for our legitimate interests, provided this does not infringe your fundamental rights. For example, analyzing feedback to improve customer satisfaction or detecting fraud may fall under this basis.

  • Explicit Consent: In cases not covered by legal grounds above, we may request your express consent. For example, using your location data for marketing or sharing your info with third-party partners requires prior approval.


Sharing of Personal Data

We may share your personal data with third parties in accordance with Articles 8 and 9 of KVKK for the following purposes:

  • Service Providers (Event/Tour Organizers): To allow use of your purchased ticket or booking, relevant information may be shared with the provider. For instance, your name may be included on the event participant list. Organizers are independent data controllers and subject to their own privacy policies.

  • Payment Institutions & Banks: Necessary data is securely transmitted to payment service providers and banks for transaction processing. This may include mandatory sharing with financial institutions like the Interbank Card Center.

  • IT, Storage & Support Service Providers: Data may be shared with local or international third parties to store information securely, manage communications, or perform analytics (e.g., cloud service providers, email/SMS platforms). Such transfers are made under contractual confidentiality obligations.

  • Legally Authorized Authorities: We may disclose your personal data when required by law or upon request by authorized judicial or administrative bodies (e.g., court orders or data protection authority inquiries).

We implement all required technical and administrative safeguards during any data transfer. Viofun is not responsible for privacy violations resulting from third parties’ failures beyond our control.


Transfer of Personal Data Abroad

Viofun aims to store your personal data within Turkey whenever possible. However, for reasons such as use of cloud services or participation in international events, your data may be transferred abroad. In such cases, we comply with Article 9 of KVKK:

  • Data may be transferred to countries with an adequate level of protection as designated by the Turkish Personal Data Protection Authority.

  • If the recipient is located in a country without such designation, data may still be transferred if they provide a written commitment to protect the data and obtain the Authority’s approval.

  • Where legally required, your explicit consent will be obtained prior to international transfers.


Method and Legal Basis of Data Collection

Your personal data is collected via digital means (e.g., our website, mobile apps, call center, email) or through physical forms. Examples:

  • Registration forms during sign-up

  • Payment details collected during purchases via secure systems

  • Cookie data gathered through site usage

Legal bases for processing include:

  • Performance of a Contract: Required for execution of our Membership Agreement or Distance Sales Contract (e.g., processing your payment and booking).

  • Legal Obligations: To comply with relevant laws (e.g., tax, consumer, e-commerce).

  • Legitimate Interest: Processing required for service improvement, fraud prevention, etc., without infringing your rights.

  • Explicit Consent: Required for processing beyond the legal bases above, such as for sending promotional messages or using location data.


Your Rights Under KVKK

According to Article 11 of KVKK, you have the right to:

  1. Learn whether your personal data is being processed,

  2. Request information if it has been processed,

  3. Learn the purpose and whether it is used accordingly,

  4. Know the third parties your data has been shared with (domestic or abroad),

  5. Request correction of incomplete or inaccurate data,

  6. Request deletion or destruction of your data under KVKK Article 7,

  7. Request notification of corrections or deletions to third parties,

  8. Object to decisions made solely through automated processing,

  9. Seek compensation for damages caused by unlawful processing.

You may exercise these rights by emailing [email protected] or submitting a written request to our company address. Your request will be responded to free of charge within 30 days, as per Article 13 of KVKK. If your request is rejected, you will receive a reasoned explanation, and you may file a complaint with the Turkish Data Protection Authority within the legally specified period.


Data Security & Retention

We implement appropriate technical and administrative measures to protect the confidentiality and security of your personal data. Data is protected through encryption (e.g., SSL), firewalls, access control, and secure infrastructure. Payment data is handled in accordance with international security standards and is not fully stored by us.

Our employees and business partners are trained and audited for compliance with our privacy policies. Personal data is retained only as long as necessary for its intended purpose or as legally required, and is securely deleted or anonymized afterward.


Contact Information

For any questions or requests concerning your rights under KVKK or your personal data, you can contact us:

Email: [email protected]
Postal Address: AOSB 3. Kısım Mah. 40. Cad. No:4, Z01, Döşemealtı / Antalya, Turkey

Your requests will be answered within 30 days as per Article 13 of KVKK. More information on personal data protection can be found in our full KVKK Disclosure Statement and Privacy Policy.


Effective Date

This KVKK Disclosure Statement was last updated in March 2025 and enters into force upon publication. Viofun reserves the right to update this document in line with future legal changes. The latest version will always be accessible via our platform.

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